2. COMMON PROBLEMS WHEN REVIEWING WATER WELL PLUGGING RECORDS

3. COMMON PROBLEMS The old well was not plugged. WAS THERE A PERMIT REQUIREMENT TO PLUG THE OLD WELL? IF SO, WHY WASN’T THE WELL PLUGGED? DID THE CONTRACTOR PROVIDE A REASON?

4. MOST COMMON REASONS FOR NOT PLUGGING THE WELL Well owner wants to keep it. Can’t locate it. Well is under driveway. Pump is stuck. These reasons are sometimes code for: “I don’t want to pay to have my well plugged.”

5. OWNER WANTS TO KEEP THE OLD WELL, NOW WHAT? Per the well code, the well owner can keep the old well. But, are they actually using it? DEQ has example letters and forms to address this with the well owner. If not, per Rule 168, you can order an abandoned well be plugged.

6. DOES THE OLD WELL FALL INTO ONE OF THESE CATEGORIES? No longer used In complete disrepair Left uncompleted Threat to groundwater resources Health or safety hazard

7. WHEN DO YOU “STICK TO YOUR GUNS” AND REQUIRE THE WELL BE PLUGGED? Well in contamination area Safety hazard Well left uncompleted due to positive coliform samples. Some LHDs take a very hard stance on this and do not approve the new well until the old well is plugged.

8. Unable to locate the well HOW MUCH EFFORT WAS PUT INTO SEARCHING FOR IT? DID YOU INQUIRE ABOUT THE WELL LOCATION WHEN YOU CONDUCTED THE PREDRILLING SITE REVIEW? COMMON PROBLEMS

9. With patience and effort, buried wells can be located.

10. COMMON PROBLEMS Some situations will be a judgment call. Use common sense and consult with DEQ if needed. WHEN DO YOU REQUIRE A WELL OWNER TO TEAR UP A CEMENT DRIVE TO FIND AND PLUG A WELL?

11. COMMON PROBLEMS A well depth of “?” or “unknown” on the plugging record. WHY DON’T THEY KNOW THE DEPTH? DID THEY MEASURE THE WELL DEPTH? IF NOT, WHY NOT? WERE THERE OBSTRUCTIONS IN THE WAY? DID THEY SEARCH FOR THE ORIGINAL DRILLING RECORD TO DETERMINE DEPTH?

12. COMMON PROBLEMS Contractors who show a pattern of stuck obstructions should be evaluated closely. ARE THEY PUTTING FORTH AN EFFORT? DO THEY HAVE THE EQUIPMENT?

13. Using and excavator or backhoe to attach to the drop pipe and yank will typically break off the drop pipe down in the well. This does not meet the intent of the well code.

14. Once the obstructions are removed, measuring the well depth is easy.

15. COMMON PROBLEMS Unapproved plugging material used.  Rock Well = Neat Cement  Sand, peastone or soil are used only in special circumstances. VIOLATION OF RULE 164

16. COMMON PROBLEMS Well owner plugging a public well or a well that is not their primary residence. Examples: apartment building hunting camp small business VIOLATION OF RULE 162

17. COMMON PROBLEMS Unregistered contractors plugging wells. pump installers or plumbers environmental consultants demolition contractors water treatment companies VIOLATION OF RULE 162

18. Demolition company illegally plugged 17 rock wells with bentonite, and did not remove the obstructions. The wells were drilled-out and re-plugged by a well drilling contractor.

19. COMMON PROBLEMS Contractor submits a dry hole drilling record with no plugging information for the dry hole. VIOLATION OF RULE 162

20. COMMON PROBLEMS Two sets of rules, one for contractors and one for well owners. THIS MAY COME BACK TO HAUNT YOU! Well owners are sometimes allowed to violate the well code when plugging their own well = SELECTIVE ENFORCEMENT.

21. Well owners do not have the knowledge or equipment to plug most wells.

22. OTHER STUFF If a contractor does not properly construct or locate a well, the contractor is responsible for plugging the well. RULE 169

23. OTHER STUFF Temporarily abandoned wells must comply with the well code. “Temporarily abandoned” wells don’t include: well too close to a contamination source well in a pit un-grouted well RULE 170

24. Submitting Known False Data on Plugging Records is a FELONY: UTTERING: Present a forged document PUBLISHING: Create a forged document &

25. Double-check all water well records for accuracy and completeness before you send them to the DEQ! PLEASE Or they will get sent back…

26. Please use our office as a resource for dealing with abandoned wells: Jim McEwan mcewanj@michigan.gov 517-241-1413 Jim’s hands-on, how-to well plugging manual is near completion!

27. QUESTIONS? Spring is just around the corner!